PAKISTAN Law and Practice Contributed by: Nadir Altaf and Muhammad Fahim Khan, RIAA Barker Gillette
regime (eg, detailed feasibility, economic, and technical studies) until NEPRA issues the techni- cal standards mandated by the NEPRA Act. As a result, the licensing regime continues in practice despite the NEPRA Act’s requirement for dereg- ulation of the generation business. With regard to power companies that were issued genera- tion licences prior to 30 April 2023, NEPRA has deemed the same to continue being regulated under the previous licensing regime. NEPRA laws Pursuant to the NEPRA Act, NEPRA has enacted and approved the following key rules, regula- tions and guidelines, which are binding upon all licensees (the “NEPRA Laws”): • NEPRA Licensing (Generation) Rules 2000 (the “Generation Licensing Rules”); • NEPRA Tariff Standards and Procedure Rules 1998 (the “Tariff Rules”); • NEPRA Licensing (Distribution) Rules 1999 (the “Distribution Licensing Rules”); • NEPRA Fines Regulations 2021 (the “Fine Regulations”); • NEPRA Licensing Application, Modification, Extension and Cancellation Procedure Regu- lations 2021 (the “AMEC Regulations”) • NEPRA Electric Power Procurement Regula- tions 2022 (the “EPP Regulations”); • NEPRA Electric Power Supplier Regulations 2022 (the “Supply Regulations”); • NEPRA Electric Power Trader Regulations 2022 (the “Trader Regulations”); • NEPRA Alternative and Renewable Energy Distributed Generation and Net Metering Regulations 2015 (the “Net Metering Regula- tions”); • NEPRA Review Procedure Regulations 2009 (the “Review Procedure Regulations”);
• NEPRA Open Access Interconnection and Wheeling of Electric Power Regulations 2022 (the “Open Access Regulations”); • NEPRA (System Operator) Regulations 2022 (the “SO Regulations”); • NEPRA Registration Regulations 2022 (the “Registration Regulations”); • NEPRA Guidelines for Determination of Con- sumer End Tariff 2015 (the “Consumer End Tariff Guidelines”); • NEPRA Guidelines for the Selection of Engineering, Procurement and Construction Contractor by Independent Power Producers 2017 (the “EPC Selection Guidelines”); • NEPRA Guidelines for the Selection of Opera- tion and Maintenance Contractors by Genera- tion Companies 2021 (the “Selection of O&M Guidelines”); • NEPRA Benchmarks for Tariff Determina- tion Guidelines 2018 (the “Tariff Benchmark Guidelines”); • Guidelines for Procurement of Coal on Spot Basis (the “Coal Procurement Guidelines”); • Guidelines to Lay Down the Methodology and Process for Determination of Revenue Requirement and Use of System Charges (UoSC) for Transmission Licensee (the “UoSC Transmission Guidelines”); • the Market Commercial Code; • the NEPRA Power Safety Code; • the Grid Code 2023; and • the Distribution Code. The foregoing list is not exhaustive and is in no particular order. Provincial regulators The province of Sindh has established a regula- tory body similar to NEPRA to regulate electric power services in Sindh named the Sindh Elec- tric Power Regulatory Authority (SEPRA). The
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